developing an in house audit program n.
Download
Skip this Video
Loading SlideShow in 5 Seconds..
Developing an In-House Audit Program PowerPoint Presentation
Download Presentation
Developing an In-House Audit Program

Loading in 2 Seconds...

play fullscreen
1 / 28

Developing an In-House Audit Program - PowerPoint PPT Presentation


  • 143 Views
  • Uploaded on

Developing an In-House Audit Program. February 28, 2006 Judy B. Yorke Yorke Engineering, LLC 949-248-8490 x25 JYorke@YorkeEngr.com. Developing Your Audit Program. What is an audit program? How do I put together an audit program? strategies audit team checklists auditing.

loader
I am the owner, or an agent authorized to act on behalf of the owner, of the copyrighted work described.
capcha
Download Presentation

PowerPoint Slideshow about 'Developing an In-House Audit Program' - etenia


An Image/Link below is provided (as is) to download presentation

Download Policy: Content on the Website is provided to you AS IS for your information and personal use and may not be sold / licensed / shared on other websites without getting consent from its author.While downloading, if for some reason you are not able to download a presentation, the publisher may have deleted the file from their server.


- - - - - - - - - - - - - - - - - - - - - - - - - - E N D - - - - - - - - - - - - - - - - - - - - - - - - - -
Presentation Transcript
developing an in house audit program

Developing an In-House Audit Program

February 28, 2006

Judy B. Yorke

Yorke Engineering, LLC

949-248-8490 x25

JYorke@YorkeEngr.com

developing your audit program
Developing Your Audit Program
  • What is an audit program?
  • How do I put together an audit program?
    • strategies
    • audit team
    • checklists
    • auditing
why do i need an audit program
Why do I need an audit program?
  • Annual Certification responsibilities
  • Citizen suits
  • Agency enforcement
    • subject to prosecution by both local and federal agencies
    • administrative, civil, and criminal
preventing problems
Preventing Problems…

Make sure your

responsible official

is comfortable

Avoid fines

and citations

Why do

I need an

audit program?

Meet the

compliance

certification

requirement

Make sure your

facility complies

with regulations

Plan corrections,

additions, improvements

to your permits

what s the bottom line
What’s the Bottom Line?
  • An great environmental audit will:
    • Improve plant profitability, by:
      • Lowering compliance costs, and
      • Increasing operating flexibility.
    • Lower compliance liability, by:
      • Correcting problems,
      • Assuring due diligence for certifications.
what an audit is or is not

Confidential

What an audit is – or is not!

An audit is:

  • Systematic
  • Demonstrates compliance
  • Rigorous
  • Critical to planning improvements to your compliance program

… But an audit is NOT Confidential

setting up an audit program

Select audit

team

Find applicable

regulations

Develop audit

checklists

Audit for

compliance

Develop

corrective action

plan

Certify to

compliance

Setting up an Audit Program
putting together an audit team
Detached and objective

Less familiar with plant

Ask “Why?”

Understands requirements

Critical to day-to-day compliance

Knowledgeable about plant

Understands impacts of imposed requirements

Has ideas about improvements or changes needed

Putting Together an Audit Team

Environmental Staff

Plant Personnel

finding applicable regulations
Finding Applicable Regulations

Agency Policy

Statements

California Health

and Safety Code

Gas Company

Audit Checklists

Federal Register

Local Agency

Rule Books

developing audit checklists general requirements
Developing Audit Checklists - General Requirements

Involve the

audited facility

Audit Checklist

Involve the

audit team

Include verification

methods

Build in documentation

methods

developing audit checklists content

User-Friendliness

  • User’s knowledge of regulations
  • User’s access to regulations
  • Avoid jargon
  • Customize for your equipment, products
Developing Audit Checklists - Content

Audit Checklist

developing audit checklists content1

Items to Audit

  • MRR requirements
  • Permit conditions
  • Trouble spots – violations, breakdowns, etc.
  • Company policies
    • Who develops policies?
    • Who carries them out?
  • Operator knowledge
Developing Audit Checklists - Content

Audit Checklist

developing audit checklists content2

Audit Components

  • Specific equipment information
  • Compliance question and answer
  • Regulatory or other citation & date
  • Verification steps
  • Compliance plan
Developing Audit Checklists - Content

Audit Checklist

developing audit checklists content3
Developing Audit Checklists - Content

Resources Needed

  • Text of regulations
  • Permits
  • Working knowledge of plant
  • Past compliance information
  • Company policies
  • Back-up resources
    • Legal
    • Technical

Audit Checklist

developing audit checklists content4

Multiple Facilities

  • Modular format
  • Allows customization
Developing Audit Checklists - Content

Audit Checklist

developing audit checklists ongoing

Updating Checklists

  • Who’s responsible?
  • How often are they updated?
  • How are regulatory changes incorporated?
Developing Audit Checklists - Ongoing

Audit Checklist

conducting an audit the process
Conducting an Audit –The Process

Get familiar

with plant

Check

paperwork

Test

conclusions

Interview

plant

personnel

conducting an audit the process1
Conducting an Audit – The Process
  • Build rapport
  • Use everything: monitoring data, reports, interviews, inspections, instincts
  • Exhaust all lines of inquiry
  • Verify major findings
  • Document what you checked, what results were
  • Document what allows you to determine compliance
conducting an audit items to check

Visually

inspect

plant

Confirm

possession

of permits

Review

permit

conditions

Review

emission

limits

Review

rule

com-

pliance

Snoop

Around!

  • Rule 219 Exempt
  • RECLAIM
  • Title V
  • NOVs/NTCs
  • Source Tests
  • Variances
  • Abatement Orders
  • Audit Reports
  • Complaints
  • Interviews
Conducting an Audit – Items to Check
briefing the responsible official
Briefing the responsible official
  • Build rapport
  • Focus on facts
  • May need to explain regulations
  • Develop solutions together
how should past noncompliance be treated
How should past noncompliance be treated?
  • EPA policy
  • Certify to ongoing, not intermittent, compliance
  • Some historical violations have current implications
must a source disclose noncompliance
Must a source disclose noncompliance?
  • Compliance plan required with permit application - so audit early!
  • May need variance to make ongoing certification
  • Other reporting requirements
    • breakdown conditions
    • reporting requirements
    • may need a permit or variance
preparing a compliance plan
Preparing a Compliance Plan
  • Need for a compliance plan
    • Helps avoid “smoking gun”
    • Required by Title V
  • What to include
    • Specific regulatory citation
    • What actions will be taken to achieve compliance
    • Date at which compliance will be achieved
  • May need to get variance
  • May need permit application
ongoing compliance assurance

Revisit audit

team selection

Update

applicable regs

Update audit

checklists

Audit for

compliance

Develop

corrective action

plan

Certify to

compliance

Ongoing Compliance Assurance
ongoing compliance assurance1
Ongoing Compliance Assurance
  • Frequency
    • Meet Title V requirements
    • consider results of past audits
    • complexity of operation/likelihood of problems
    • may want to do “spot” audits
    • consider EPA audit policy
  • Updating checklists
    • make sure regulations haven’t changed
    • first one after Title V application is completed: make sure all your permit conditions are included
making compliance second nature
Making Compliance Second Nature
  • Build Auditable Systems
    • consider setting up internal systems to make auditing easier
      • regular recordkeeping
      • regular inspections and logging of inspections
  • Management Attitude
    • Audit protects company, employees
    • Avoid scape-goating
making compliance second nature1
Making Compliance Second Nature

recognize

and reward

“clean”

audits

educate

staff on

Title V

recognize/reward identification and correction of

noncompliance

responsibleofficialobligations

Get plant people

on board

recognize

and reward

just doing

audits!

explain

penalties

give staff training

and time to maintain

compliance

give them

time to audit

Staff

responsibilities

commitment to assistance
Commitment to Assistance

The Gas Company is Committed to Assisting Our Customers Throughout the Title V Process Call for Questions or Assistance!

562-803-7428